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Kingdom of Norway

Kingdom of Norway

Deposited on 17 2019

Kingdom of

Status of List of Reservations and Notifications upon Deposit of the Instrument of Ratification

This document contains the list of reservations and notifications made by Norway upon deposit of the instrument of ratification pursuant to Articles 28(5) and 29(1) of the Convention.

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Article 2 – Interpretation of Terms

Notification - Agreements Covered by the Convention

Pursuant to Article 2(1)(a)(ii) of the Convention, Norway wishes the following agreement(s) to be covered by the Convention:

Other Original/ Date of Date of Entry No Title Contracting Amending Signature into Force Jurisdiction Instrument 1 Convention between The Kingdom of Original 08-10-1997 30-11-2001 Norway and the of Argentina for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and on Capital 2 Convention between the Kingdom of Original 08-08-2006 12-09-2007 Norway and Australia for the avoidance of double taxation with respect to taxes on income and the prevention of fiscal evasion 3 Convention between the Kingdom of Original 22-07-2014 30-07-2015 Norway and the Republic of Bulgaria for the avoidance of double taxation with respect to taxes on income 4 Convention between the Kingdom of Chile Original 26-10-2001 22-07-2003 Norway and the Republic of Chile for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital 5 Agreement between the Government Original 25-02-1986 21-12-1986 of the and the Government of the People’s Republic of China for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital 6 Convention between the Kingdom of Original 24-02-2014 08-07-2014 Norway and the Republic of Cyprus for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income 7 Convention between the government Czech Original 19-10-2004 09-09-2005 of the Kingdom of Norway and the Republic Government of the for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income 8 Convention between The Kingdom of Original 14-05-1993 30-12-1993 Norway and The Republic of Estonia for the avoidance of double taxation

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and the prevention of fiscal evasion with respect to taxes on income and on capital 9 Agreement between The Kingdom of Original 10-11-2011 23-07-2012 Norway and Georgia for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income 10 Convention between The Kingdom of Original 27-04-1988 16-09-1991 Norway and The Hellenic Republic for the avoidance of double taxation and the prevention of fiscal evasion with Amending 06-06-1998 01-01-1999 respect to taxes on income and on notification capital 11 Agreement between the Kingdom of India Original 02-02-2011 20-12-2011 Norway and the Republic of India for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital 12 Convention between the Kingdom of Ireland Original 22-11-2000 28-11-2001 Norway and Ireland for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to taxes on income and on capital 13 Convention between the Kingdom of Original 04-03-1992 16-12-1992 Norway and Japan for the avoidance of double taxation and prevention of fiscal evasion with respect to taxes on income 14 Convention between the Kingdom of Original 19-07-1993 30-12-1993 Norway and the Republic of Latvia for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital 15 Convention between The Kingdom of Original 27-04-1993 30-12-1993 Norway and The Republic of Lithuania for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital 16 Overenskomst mellom Kongeriket Original 06-05-1983 27-02-1985 Norge og Storhertugdømmet Luxembourg til unngåelse av Amending 07-07-2009 12-04-2010 dobbeltbeskatning og Protocol skatteunndragelse med hensyn til Amending 25-12-1998 01-01-1999 skatter av inntekt og formue instrument

Convention entre le Royaume de Norvège et le Grand-Duché de Luxembourg tendant à éviter les doubles impositions et à prévenir

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l’évasion fiscale en matière d’impôts sur le revenu et sur la fortune 17 Convention between the Kingdom of Original 30-03-2012 14-02-2013 Norway and Malta for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to taxes on income 18 Overenskomst mellom Kongeriket Original 23-03-1995 23-01-1996 Norge og Mexicos Forente Stater til unngåelse av dobbeltbeskatning og forebyggelse av skatteunndragelse med hensyn til skatter av inntekt og formue1

Convenio entre el reino de Noruega y los Estados Unidos Mexicanos para evitar la doble imposición e impedir la evasión fiscal en materia de impuestos sobre la renta y sobre el patrimonio 19 Convention between the Kingdom of The Original 12-01-1990 31-12-1990 Norway and the Kingdom of the Netherlands for the avoidance of double taxation and the prevention Amending 23-04-2013 30-11-2013 of fiscal evasion with respect to taxes Protocol on income and on capital 20 Convention between the Kingdom of Original 09-09-2009 25-05-2010 Norway and the Republic of Poland for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income Amending 05-07-2012 02-04-2013 Protocol 21 Convention between the kingdom of Original 10-03-2011 15-06-2012 Norway and the Portuguese republic for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income 22 Convention between the kingdom of Original 27-04-2015 01-04-2016 Norway and Romania for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income 23 Convention between The Kingdom of Original 26-03-1996 20-12-2002 Norway and The Russian Federation For the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital 24 Convention between the Kingdom of Original 17-06-2015 18-12-2015 Norway and the Republic of Serbia for the Avoidance of Double Taxation

1 Unofficial translation: “Agreement between the Kingdom of Norway and the United Mexican States to avoid double taxation and prevent tax evasion with respect to taxes on income and on capital”

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and the Prevention of Fiscal Evasion with Respect to Taxes on Income 25 Convention between the Kingdom of Original 18-02-2008 10-12-2009 Norway and the Republic of Slovenia for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income 26 Convention between the Kingdom of Africa Original 12-02-1996 12-09-1996 Norway and the Republic of South Africa for the Avoidance of Double Taxation and the Prevention of Fiscal Amending 16-07-2012 20-11-2015 Evasion with respect to taxes on Protocol income 27 Convention between the Kingdom of Original 15-01-2010 15-06-2011 Norway and the Republic of Turkey for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income 28 Convention Between The Kingdom of United Original 14-03-2013 17-12-2013 Norway and The of Kingdom and for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to taxes on income and on capital gains

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Article 3 – Transparent Entities

Reservation

Pursuant to Article 3(5)(b) of the Convention, Norway reserves the right for paragraph 1 not to apply to its Covered Tax Agreements that already contain a provision described in Article 3(4). The following agreement(s) contain(s) provisions that are within the scope of this reservation.

Listed Agreement Number Other Contracting Jurisdiction Provision 11 India Article 4(1)(b)

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Article 4 – Dual Resident Entities

Reservation

Pursuant to Article 4(3)(d) of the Convention, Norway reserves the right for the entirety of Article 4 not to apply to its Covered Tax Agreements that already cases where a person other than an individual is a resident of more than one Contracting Jurisdiction by requiring the competent authorities of the Contracting Jurisdictions to endeavour to reach mutual agreement on a single Contracting Jurisdiction of residence, and that set out the treatment of that person under the Covered Tax Agreement where such an agreement cannot be reached. The following agreement(s) contain(s) provisions that are within the scope of this reservation.

Listed Agreement Number Other Contracting Jurisdiction Provision 3 Bulgaria Article 4(3) 4 Chile Article 4(3) 6 Cyprus Article 4(3) 8 Estonia Article 4(3) 14 Latvia Article 4(3) 15 Lithuania Article 4(3) 22 Romania Article 4(3) 24 Serbia Article 4(3) 28 United Kingdom Article 4(4)

Notification of Existing Provisions in Listed Agreements

Pursuant to Article 4(4) of the Convention,Norway considers that the following agreement(s) contain(s) a provision described in Article 4(2) that is not subject to a reservation under Article 4(3)(b) through (d). The article and paragraph number of each such provision is identified below.

Listed Agreement Number Other Contracting Jurisdiction Provision 1 Argentina Article 4(3) 2 Australia Article 4(4) 5 China Article 4(3) 7 Czech Republic Article 4(3) 9 Georgia Article 4(3) 10 Greece Article 4(3) 11 India Article 4(3) 12 Ireland Article 4(3) 13 Japan Article 4(3) 16 Luxembourg Article 4(3) 17 Malta Article 4(3) 18 Mexico Article 4(3) 19 The Netherlands Article 4(3) 20 Poland Article 4(3) 21 Portugal Article 4(3) 23 Russia Article 4(3) and (4) 25 Slovenia Article 4(3) 26 South Africa Article 4(3) 27 Turkey Article 4(3)

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Article 5 – Application of Methods for Elimination of Double Taxation

Notification of Choice of Optional Provisions

Pursuant to Article 5(10) of the Convention, Norway hereby chooses under Article 5(1) to apply Option C of that Article.

Notification of Existing Provisions in Listed Agreements

For jurisdictions choosing Option C:

Pursuant to Article 5(10) of the Convention, Norway considers that the following agreement(s) contain(s) a provision described in Article 5(7). The article and paragraph number of each such provision is identified below.

Listed Agreement Number Other Contracting Jurisdiction Provision 5 China Article 25(2)

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Article 6 – Purpose of a Covered Tax Agreement

Notification of Choice of Optional Provisions

Pursuant to Article 6(6) of the Convention, Norway hereby chooses to apply Article 6(3).

Notification of Existing Preamble Language in Listed Agreements

Pursuant to Article 6(5) of the Convention, Norway considers that the following agreement(s) is(are) not within the scope of a reservation under Article 6(4) and contain(s) preamble language described in Article 6(2). The text of the relevant preambular paragraph is identified below.

Listed Other Agreement Contracting Preamble Text Number Jurisdiction Argentina desiring to conclude a Convention for the Avoidance of 1 Double Taxation and the Prevention of Fiscal Evasion with respect to taxes on income and on capital, Australia desiring to conclude a Convention for the avoidance of double 2 taxation with respect to taxes on income and the prevention of fiscal evasion, Bulgaria desiring to conclude a Convention for the avoidance of double taxation with respect to taxes on income in order to promote 3 and strengthen the economic relations between the two States, Chile desiring to conclude a Convention for the avoidance of double 4 taxation and the prevention of fiscal evasion with respect to taxes on income and on capital, China Desiring to conclude an Agreement for the avoidance of 5 double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital, Cyprus desiring to conclude a Convention for the Avoidance of 6 Double Taxation and the Prevention of Fiscal Evasion with respect to taxes on income, Czech Republic desiring to conclude a Convention for the Avoidance of 7 Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income, Estonia Desiring to conclude a Convention for the avoidance of double 8 taxation and the prevention of fiscal evasion with respect to taxes on income and on capital, Georgia desiring to conclude an Agreement for the Avoidance of 9 Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income, Greece desiring to conclude a Convention for the Avoidance of 10 Double Taxation and the Prevention of Fiscal Evasion with respect to taxes on income and on capital, India desiring to conclude an Agreement for the avoidance of 11 double taxation and the prevention of fiscal evasion with

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respect to taxes on income and on capital and with a view to promoting economic cooperation between the two countries, Ireland desiring to conclude a Convention for the Avoidance of 12 Double Taxation and the Prevention of Fiscal Evasion with respect to taxes on income and on capital, Japan Desiring to conclude a Convention for the avoidance of double 13 taxation and the prevention of fiscal evasion with respect to taxes on income, Latvia Desiring to conclude a Convention for the avoidance of double taxation and the prevention of fiscal evasion with respect to 14 taxes on income and on capital,

Lithuania Desiring to conclude a Convention for the avoidance of double 15 taxation and the prevention of fiscal evasion with respect to taxes on income and on capital, Luxembourg som ønsker å unngå dobbeltbeskatning og forebygge skatteunndragelse med hensyn til skatter av inntekt og formue, har besluttet å inngå en overenskomst og har i dette øyemed oppnevnt som sine befullmektigede: Kongeriket Norges Regjering: Hans Kongelige Høyhet Storhertugen av Luxembourg: 16 Som etter å ha utvekslet sine fullmakter, som er funnet i god og riktig form,:

animés du désir d’éviter les doubles impositions et de prévenir l’évasion fiscale en matière d’impôts sur le revenu et sur la fortune, ont décidé de conclure une convention et ont nommé à cet effet pour leurs plénipotentiaires, savoir: Malta desiring to conclude a Convention for the avoidance of double 17 taxation and the prevention of fiscal evasion with respect to taxes on income, Mexico som ønsker å inngå en overenskomst til unngåelse av dobbeltbeskatning og forebyggelse av skatteunndragelse med hensyn til skatter av inntekt og formue, 18 deseando concluir un Convenio para Evitar la Doble Imposición e Impedir la Evasión Fiscal en materia de impuestos sobre la renta y sobre el patrimonio, The Netherlands desiring to conclude a new Convention for the avoidance of 19 double taxation and the prevention of fiscal evasion with respect to taxes on income, Poland desiring to conclude a Convention for the avoidance of double 20 taxation and the prevention of fiscal evasion with respect to taxes on income; Portugal Desiring to conclude a Convention for the avoidance of double 21 taxation and the prevention of fiscal evasion with respect to taxes on income, Romania Desiring to conclude a Convention for the Avoidance of 22 Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income,

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Russia desiring to conclude a Convention for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with 23 respect to taxes on income and on capital, and with a view to promote economic cooperation between the two countries, Serbia desiring to conclude a Convention for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income, with the view to establishing 24 stable conditions for comprehensive development of economic cooperation and investment between the two countries, Slovenia desiring to conclude a Convention for the avoidance of double 25 taxation and the prevention of fiscal evasion with respect to taxes on income South Africa desiring to conclude a Convention for the Avoidance of 26 Double Taxation and the Prevention of Fiscal Evasion with respect to taxes on income, Turkey desiring to conclude a Convention for the Avoidance of 27 Double Taxation and the Prevention of Fiscal Evasion with respect to taxes on income, United desiring to conclude a Convention for the Avoidance of 28 Kingdom Double Taxation and the Prevention of Fiscal Evasion with respect to taxes on income and on capital gains,

Notification of Listed Agreements Not Containing Existing Preamble Language

Pursuant to Article 6(6) of the Convention, Norway considers that the following agreement(s) do(es) not contain preamble language referring to a desire to develop an economic relationship or to enhance co-operation in tax matters.

Listed Agreement Number Other Contracting Jurisdiction 1 Argentina 2 Australia 3 Bulgaria 4 Chile 5 China 6 Cyprus 7 Czech Republic 8 Estonia 9 Georgia 10 Greece 11 India 12 Ireland 13 Japan 14 Latvia 15 Lithuania 16 Luxembourg 17 Malta 18 Mexico

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19 The Netherlands 20 Poland 21 Portugal 22 Romania 24 Serbia 25 Slovenia 26 South Africa 27 Turkey 28 United Kingdom

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Article 7 – Prevention of Abuse

Statement of Acceptance of the PPT as an Interim Measure

Pursuant to Article 7(17)(a) of the Convention, Norway hereby expresses a statement that while Norway accepts the application of Article 7(1) alone as an interim measure, it intends where possible to adopt a limitation on benefits provision, in addition to or in replacement of Article 7(1), through bilateral negotiation.

Notification of Choice of Optional Provisions

Pursuant to Article 7(17)(d) of the Convention, Norway hereby chooses to apply Article 7(7)(a).

Notification of Existing Provisions in Listed Agreements

Pursuant to Article 7(17)(a) of the Convention, Norway considers that the following agreement(s) is(are) not subject to a reservation described in Article 7(15)(b) and contain(s) a provision described in Article 7(2). The article and paragraph number of each such provision is identified below.

Listed Agreement Number Other Contracting Jurisdiction Provision 2 Australia Articles 10(7), 11(9) and 12(7) Articles 10(7), 11(8), 12(7) and 3 Bulgaria 21(3) 4 Chile Articles 11(7) and 12(7) Articles 10(7), 11(5), 12(5) and 9 Georgia 20(3) 11 India Article 29 12 Ireland Articles 11(6) and 12(6) 17 Malta Article 10(7) 18 Mexico Articles 11(9), 12(7) 22 Romania Articles 10(7), 11(8), 12(7) Articles 10(7), 11(8), 12(7) and 24 Serbia 22(4) Articles 10(7), 11(5), 12(5) and 28 United Kingdom 20(5)

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Article 8 – Dividend Transfer Transactions

Reservation

Pursuant to Article 8(3)(b)(i) of the Convention, Norway reserves the right for the entirety of Article 8 not to apply to its Covered Tax Agreements to the extent that the provisions described in Article 8(1) already include a minimum holding period. The following agreement(s) contain(s) provisions that are within the scope of this reservation.

Listed Agreement Number Other Contracting Jurisdiction Provision 2 Australia Article 10(3) 13 Japan Article 10(2)(a) 17 Malta Article 10(2)(a)(i) 20 Poland Article 10(2)(a) 21 Portugal Article 10(2)(a)

Notification of Existing Provisions in Listed Agreements

Pursuant to Article 8(4) of the Convention,Norway considers that the following agreement(s) contain(s) a provision described in Article 8(1) that is not subject to a reservation described in Article 8(3)(b). The article and paragraph number of each such provision is identified below.

Listed Agreement Number Other Contracting Jurisdiction Provision 1 Argentina Article 10(2)a) 2 Australia Article 10(2)(a) 3 Bulgaria Article 10(2)(a) 4 Chile Article 10(2)(a) 5 China N/A 6 Cyprus Article 10(2)(a) 7 Czech Republic Article 10(2)a) 8 Estonia Article 10(2)(a) 9 Georgia Article 10(2)a) 10 Greece Article 10(2)(a) and (b) 11 India N/A 12 Ireland Article 10(2)(a) 14 Latvia Article 10(2)(a) 15 Lithuania Article 10(2)(a) 16 Luxembourg Article 10(2)(a) 18 Mexico Article 10(3) 19 The Netherlands Aricle 10(3)(b) 22 Romania Article 10(2)(a) 24 Serbia Article 10(2)(1) 25 Slovenia Article 10(2)(a) and (b) 26 South Africa Article 10(2)(a) 27 Turkey Article 10(2)(a) 28 United Kingdom Article 10(2)(b)(i)

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Article 9 – Capital Gains from Alienation of Shares or Interests of Entities Deriving their Value Principally from Immovable Property

Reservation

Pursuant to Article 9(6)(a) of the Convention, Norway reserves the right for Article 9(1) not to apply to its Covered Tax Agreements.

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Article 10 – Anti-abuse Rule for Permanent Establishments Situated in Third Jurisdictions

Reservation

Pursuant to Article 10(5)(a) of the Convention, Norway reserves the right for the entirety of Article 10 not to apply to its Covered Tax Agreements.

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Article 12 – Artificial Avoidance of Permanent Establishment Status through Commissionnaire Arrangements and Similar Strategies

Notification of Existing Provisions in Listed Agreements

Pursuant to Article 12(5) of the Convention, Norway considers that the following agreement(s) contain(s) a provision described in Article 12(3)(a). The article and paragraph number of each such provision is identified below.

Listed Agreement Number Other Contracting Jurisdiction Provision 1 Argentina Article 5(5) 2 Australia Article 5(6) 3 Bulgaria Article 5(6) 4 Chile Article 5(5) 5 China Article 5(5) 6 Cyprus Article 5(6) 7 Czech Republic Article 5(5) 8 Estonia Article 5(5) 9 Georgia Article 5(6) 10 Greece Article 5(5) 11 India Article 5(5)(a) 12 Ireland Article 5(5) 13 Japan Article 5(5) 14 Latvia Article 5(5) 15 Lithuania Article 5(5) 16 Luxembourg Article 5(5) 17 Malta Article 5(6) 18 Mexico Article 5(5) 19 The Netherlands Article 5(6) 20 Poland Article 5(6) 21 Portugal Article 5(6) 22 Romania Article 5(6) 23 Russia Article 5(4) 24 Serbia Article 5(7) 25 Slovenia Article 5(6) 26 South Africa Article 5(5) 27 Turkey Article 5(6) 28 United Kingdom Article 5(6)

Pursuant to Article 12(6) of the Convention, Norway considers that the following agreement(s) contain(s) a provision described in Article 12(3)(b). The article and paragraph number of each such provision is identified below.

Listed Agreement Number Other Contracting Jurisdiction Provision 1 Argentina Article 5(6) 2 Australia Article 5(7) 3 Bulgaria Article 5(7) 4 Chile Article 5(7)

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5 China Article 5(6) 6 Cyprus Article 5(7) 7 Czech Republic Article 5(6) 8 Estonia Article 5(6) 9 Georgia Article 5(7) 10 Greece Article 5(6) 11 India Article 5(7) 12 Ireland Article 5(6) 13 Japan Article 5(6) 14 Latvia Article 5(6) 15 Lithuania Article 5(6) 16 Luxembourg Article 5(6) 17 Malta Article 5(7) 18 Mexico Article 5(7) 19 The Netherlands Article 5(7) 20 Poland Article 5(7) 21 Portugal Article 5(7) 22 Romania Article 5(7) 23 Russia Article 5(5) 24 Serbia Article 5(8) 25 Slovenia Article 5(7) 26 South Africa Article 5(6) 27 Turkey Article 5(7) 28 United Kingdom Article 5(7)

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Article 13 – Artificial Avoidance of Permanent Establishment Status through the Specific Activity Exemptions

Notification of Choice of Optional Provisions

Pursuant to Article 13(7) of the Convention, Norway hereby chooses to apply Option A under Article 13(1).

Notification of Existing Provisions in Listed Agreements

Pursuant to Article 13(7) of the Convention, Norway considers that the following agreement(s) contain(s) a provision described in Article 13(5)(a). The article and paragraph number of each such provision is identified below.

Listed Agreement Number Other Contracting Jurisdiction Provision 1 Argentina Article 5(4) 2 Australia Article 5(5) 3 Bulgaria Article 5(5) 4 Chile Article 5(4) 5 China Article 5(4) 6 Cyprus Article 5(5) 7 Czech Republic Article 5(4) 8 Estonia Article 5(4) 9 Georgia Article 5(5) 10 Greece Article 5(4) 11 India Article 5(4) 12 Ireland Article 5(4) 13 Japan Article 5(4) 14 Latvia Article 5(4) 15 Lithuania Article 5(4) 16 Luxembourg Article 5(4) 17 Malta Article 5(5) 18 Mexico Article 5(4) 19 The Netherlands Article 5(5) 20 Poland Article 5(5) 21 Portugal Article 5(5) 22 Romania Article 5(5) 23 Russia Article 5(3) 24 Serbia Article 5(6) 25 Slovenia Article 5(5) 26 South Africa Article 5(4) 27 Turkey Article 5(5) 28 United Kingdom Article 5(5)

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Article 14 – Splitting-up of Contracts

Reservation

Pursuant to Article 14(3)(b) of the Convention, Norway reserves the right for the entirety of Article 14 not to apply with respect to provisions of its Covered Tax Agreements relating to the for or exploitation of natural resources. The following agreement(s) contain(s) provisions that are within the scope of this reservation.

Listed Agreement Number Other Contracting Jurisdiction Provision 1 Argentina Articles 5(3)(d) and 21(4) 2 Australia Article 20(3) 3 Bulgaria Article 20(3) 5 China Article 23(4) 6 Cyprus Article 20 (3) 7 Czech Republic Article 20(3) 8 Estonia Article 21(3) 11 India Article 21(3) 12 Ireland Article 21(3) 13 Japan Article 21(2) 14 Latvia Article 21(3) 15 Lituania Article 21(3) Paragraph 2 of the Additional 16 Luxembourg Protocol 17 Malta Article 20(3) 18 Mexico Article 21(4) 19 The Netherlands Article 24(3) 20 Poland Article 20(4) 21 Portugal Article 21(3) 22 Romania Article 21(3) 23 Russia Paragraph 3 of the Protocol 24 Serbia Article 21(3) 25 Slovenia Article 20(3) 26 South Africa Article 21(3) 27 Turkey Article 21(3) 28 United Kingdom Article 21(4)

Notification of Existing Provisions in Listed Agreements

Pursuant to Article 14(4) of the Convention, Norway considers that the following agreement(s) contain(s) a provision described in Article 14(2) that is not subject to a reservation under Article 14(3)(b). The article and paragraph number of each such provision is identified below.

Listed Agreement Number Other Contracting Jurisdiction Provision 2 Australia Article 5(4) 19 The Netherlands Article III of the Protocol 24 Serbia Article 5(5)

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Article 16 – Mutual Agreement Procedure

Notification of Existing Provisions in Listed Agreements

Pursuant to Article 16(6)(a) of the Convention, Norway considers that the following agreement(s) contain(s) a provision described in Article 16(4)(a)(i). The article and paragraph number of each such provision is identified below.

Listed Agreement Number Other Contracting Jurisdiction Provision 1 Argentina Article 26(1), first sentence 2 Australia Article 25(1), first sentence 3 Bulgaria Article 24(1), first sentence 4 Chile Article 25(1), first sentence 5 China Article 27(1), first sentence 6 Cyprus Article 24(1), first sentence 7 Czech Republic Article 24(1), first sentence 8 Estonia Article 26(1), first sentence 9 Georgia Article 23(1), first sentence 10 Greece Article 26(1), first sentence 11 India Article 26(1), first sentence 12 Ireland Article 26(1), first sentence 13 Japan Article 25(1), first sentence 14 Latvia Article 26(1), first sentence 15 Lithuania Article 26(1), first sentence 16 Luxembourg Article 25(1) 17 Malta Article 24(1), first sentence Article 26(1), first sentence and second sentence of the 18 Mexico Norwegian text and Article 26(1), first sentence of the Spanish text 19 The Netherlands Article 26(1), first sentence 20 Poland Article 24(1), first sentence 21 Portugal Article 25(1), first sentence 22 Romania Article 25(1), first sentence 23 Russia Article 25(1), first sentence 24 Serbia Article 25(1), first sentence 25 Slovenia Article 24(1), first sentence 26 South Africa Article 25(1), first sentence 27 Turkey Article 25(1), first sentence 28 United Kingdom Article 27(1), first sentence

Pursuant to Article 16(6)(b)(ii) of the Convention, Norway considers that the following agreement(s) contain(s) a provision that provides that a case referred to in the first sentence of Article 16(1) must be presented within a specific time period that is at least three years from the first notification of the action resulting in taxation not in accordance with the provisions of the Covered Tax Agreement. The article and paragraph number of each such provision is identified below.

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Listed Agreement Number Other Contracting Jurisdiction Provision 1 Argentina Article 26(1), second sentence 2 Australia Article 25(1), second sentence 3 Bulgaria Article 24(1), second sentence 5 China Article 27(1), second sentence 6 Cyprus Article 24(1), second sentence 7 Czech Republic Article 24(1), second sentence 8 Estonia Article 26(1), second sentence 9 Georgia Article 23(1), second sentence 10 Greece Article 26(1), second sentence 11 India Article 26(1), second sentence 12 Ireland Article 26(1), second sentence 13 Japan Article 25(1), second sentence 14 Latvia Article 26(1), second sentence 15 Lithuania Article 26(1), second sentence 17 Malta Article 24(1), second sentence Article 26(1), third sentence of 18 Mexico the Norwegian text and second sentence of the Spanish text. 19 The Netherlands Article 26(1), second sentence 20 Poland Article 24(1), second sentence 21 Portugal Article 25(1), second sentence 22 Romania Article 25(1), second sentence 23 Russia Article 25(1), second sentence 24 Serbia Article 25(1), second sentence 25 Slovenia Article 24(1), second sentence 26 South Africa Article 25(1), second sentence 27 Turkey Article 25(1), second sentence 28 United Kingdom Article 27(1), second sentence

Notification of Listed Agreements Not Containing Existing Provisions

Pursuant to Article 16(6)(c)(i) of the Convention, Norway considers that the following agreement(s) do(es) not contain a provision described in Article 16(4)(b)(i).

Listed Agreement Number Other Contracting Jurisdiction 18181188 Mexico

Pursuant to Article 16(6)(c)(ii) of the Convention, Norway considers that the following agreement(s) do(es) not contain a provision described in Article 16(4)(b)(ii).

Listed Agreement Number Other Contracting Jurisdiction 4 Chile 18 Mexico

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Pursuant to Article 16(6)(d)(ii) of the Convention, Norway considers that the following agreement(s) do(es) not contain a provision described in Article 16(4)(c)(ii).

Listed Agreement Number Other Contracting Jurisdiction 4 Chile 18 Mexico 21 Portugal

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Article 17 – Corresponding Adjustments

Reservation

Pursuant to Article 17(3)(a) of the Convention, Norway reserves the right for the entirety of Article 17 not to apply to its Covered Tax Agreements that already contain a provision described in Article 17(2). The following agreement(s) contain(s) provisions that are within the scope of this reservation.

Listed Agreement Number Other Contracting Jurisdiction Provision 1 Argentina Article 9(2) 2 Australia Article 9(3) 3 Bulgaria Article 9(2) 4 Chile Article 9(2) 6 Cyprus Article 9(2) 7 Czech Republic Article 9(2) 8 Estonia Article 9(2) 9 Georgia Article 9(2) 11 India Article 9(2) 13 Japan Article 9(2) 14 Latvia Article 9(2) 15 Lithuania Article 9(2) 17 Malta Article 9(2) 19 The Netherlands Article 9(2) 20 Poland Article 9(2) 21 Portugal Article9(2) 22 Romania Article 9(2) 23 Russia Article 9(2) 24 Serbia Article 9(2) 25 Slovenia Article 9(2) 26 South Africa Aricle 9(2) 27 Turkey Article 9(2) 28 United Kingdom Article 9(2)

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Article 35 – Entry into Effect

Reservation

Pursuant to Article 35(6) of the Convention, Norway reserves the right for Article 35(4) not to apply with respect to its Covered Tax Agreements.

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